Regulations interpretations and countries differences

[Fri3Oil System]

Hi,

after almost 2 yrs here, I start my first proper thread, (this time not advertising ) so folks, be gentle My apologies if this subject has been already discussed in other threads, I didn't see it.

My question is regarding the different interpretations and restrictions some regulations suffer in different EU countries.

Regarding E.R.1005/2009, installers are allowed to use recycled and/or regenerated R22 for maintenance until end of 2014. The thing is, an installer can recover R22 from a plant, recycle it, either on site or at his facilities, and the reuse it at other client's installation, isn't it?

This is the way we are working in Spain, and as fas as I know in Portugal or UK.
http://www.mma.es/secciones/calidad_contaminacion/atmosfera/ozono/pdf/091212_Presentacion_MARM_v_imprimir.pdf
This is a link to a presentation of the Spanish Ministry of the Environment in which they clearly explain this.

In other countries, like in Belgium, it seems to be specifically forbidden to carry out this task: recover at owner A, recycle, and reuse at owner B.

1. Can anyone properly ensure this?
2. Can also anyone let me know if this case is similar in other EU countries?

There are thousands of R22 tons in the existing plants, and, should we like to get rid of R22 in an environmentally responsible way, not emitting it, we should take advantage of the existing gas, by allowing you professionals to recover and recycle with your own tools, and reusing if for leaks replacements, or flushing maintenance, i.e.

Besides, when there is an installation which used to have R22, and now it's leaked, how can you remove the mineral oil from it, when you won't have any available R22 for maintenance? HCFc's are the only gases which are miscible/soluble with MO, therefore, the only ones that can remove it totally.

Thanks for your readings and answers chaps,

Regards,

Nando.

[sedgy]

bienas dias Nando,
being a retiered engineer, and living in your delightfull country, I am still amaised at the wanten waste
ie blowing off of gas< R22< I demonstated with the owner of the store< whos engineer was responsable< but with no avail , in my reasonable spanish , I knew I was getting to him when he switched to mallorcian, there he lost me, and so, any advice ? sedgy

[NoNickName]

Recovered and regenerated are not synonims.
Recovered R22 can be charged only in the same site and unit where it was removed.
Regenerated R22 can be used anywhere. Regeneration shall be performed only by authorised collecting and reprocessing facilities.
Moving R22 around is a felony, because R22 is deemed a dangerous waste. Only approved collectors can pick up R22 and regenerate it.
Same with asbestos in the old times.

[Fri3Oil System]

Hi NNN,

I have not spoken about recovered and regenerated R22, but recycled and regenerated. I know perfectly the difference between recycling and regeneration, you should know it as well. A recycled product is not a waste, but a recycled product. R22 itself is not a waste, as long as it is separated from the oil and other impurities that come from the installation.
Recovered R22 is a residue and so, it should be treated by an authorised collector/waste dealer or by the installer, if he has the right methods to recycle it. This is what the Spanish Ministry of the Environment has interpreted from E.R. 1005/2009, and my wonder here is if in other countries the Authorities have interpreted similar things. Because it makes more sense to take advantage of all the existing R22, instead of incinerating it, or just releasing, as it happens daily in many countries.

In Spain, our Ministry of the Environment and the Environmental Police really take care about this issue, and are now controlling tightly if there is ilegal R22 around, like stocks, or not properly regenerated one.
I wanted to know, if in other countries, there is a similar concern about.

regards,

Nando.

[NoNickName]

Ok, there is a misinterpretation. Let's use the correct english terms:
23. "recovery" means the collection and the storage of controlled substances from products and equipment or containers during maintenance or servicing or before disposal;

24. "recycling" means the reuse of a recovered controlled substance following a basic cleaning process;

25. "reclamation" means the reprocessing of a recovered controlled substance in order to meet the equivalent performance of a virgin substance, taking into account its intended use;


Reclaimed hydrochlorofluorocarbons may be placed on the market and used for the maintenance or servicing of existing refrigeration, air-conditioning and heat pump equipment, provided that the container is labelled with an indication that the substance has been reclaimed and with information on the batch number and name and address of the reclamation facility.

Until 31 December 2014, recycled hydrochlorofluorocarbons may be used for the maintenance or servicing of existing refrigeration, air-conditioning and heat pump equipment provided that they have been recovered from such equipment and may only be used by the undertaking which carried out the recovery as part of maintenance or servicing or for which the recovery as part of maintenance or servicing was carried out.

Regenerated actually doesn't exist.

[monkey spanners]

This is my understanding,

As a contractor in the UK, i can either recover it a site and use it at that site either in the same system or another system opperated by the same owner, or i have to send it back to the manufacturers for cleaning/recycling.

I can't clean it myself and re sell to other sites or owners/customers.

Jon

[Fri3Oil System]

Reclaimed hydrochlorofluorocarbons may be placed on the market and used for the maintenance or servicing of existing refrigeration, air-conditioning and heat pump equipment, provided that the container is labelled with an indication that the substance has been reclaimed and with information on the batch number and name and address of the reclamation facility.

Until 31 December 2014, recycled hydrochlorofluorocarbons may be used for the maintenance or servicing of existing refrigeration, air-conditioning and heat pump equipment provided that they have been recovered from such equipment and may only be used by the undertaking which carried out the recovery as part of maintenance or servicing or for which the recovery as part of maintenance or servicing was carried out.

The interpretation we make is that the recycled product you can reuse for the maintenance and service of equipments can only be brought from existing refrigeration, air-conditioning and heat pump, but it does not mean it has to be used on the same equipments. It is just not logic to recover and recycle R22 from a plant, and insert it at the same plant again, when the goal is to eliminate HCFC's. What it means, or what we think it means is that the origin of recycled product cannot be a stock or a product that comes from anywhere else than these RAC&H equipments.
And sorry about my nomenclature, reclamation in Spanish is "regeneración", similar as in Italian I guess.

Our concern is to make people in general notice that it is not logic at all to recover from a plant and put it back at the same plant, and this is the point I wanted to debate here, because I have been told that this is specifically forbidden in some countries.

Maybe, the regulation is not clear enough or it can be ambiguous depending on each member's translation, so, it should be interpreted with some common sense.

I hope anyway, I expressed myself better this time.

regards,

Nando.

[Fri3Oil System]

This is my understanding,

As a contractor in the UK, i can either recover it a site and use it at that site either in the same system or another system opperated by the same owner, or i have to send it back to the manufacturers for cleaning/recycling.

I can't clean it myself and re sell to other sites or owners/customers.

Jon

Hi Jon,

You cannot re-sell recycled R22. You can only buy and sell reclaimed one. This is the R22 you take to an authorised collector that reclaims it, and resells it to you.
Regarding our interpretation (Spain as a country, not me or my company): You can recover R22, recycle it and reuse it in different owner's plant. You don't sell R22, but labour, service, maintenance, etc. And this recycling can be carried out either on site, or at your facilities. Then, you can't re-sell it to other parties, because you are not an authorised waste collector, and you are not dealing with reclaimed R22, but recycled.

Regards,

Nando.